Tax News: dividing-up of SCI shares: a strictly limited tool! 1/2

Charging of losses on land: the prerogative of the usufructuary or of the bare owner?

In 2016, we have seen a number of decisions concerning the use of dividing up the ownership – which under French law consists of splitting full ownership of an asset into 2 distinct rights: usufruct and bare ownership – of shares in an SCI (société civile immobilière, real estate partnership).

In particular, the Administrative Court of Appeal (“ACA”) of Bordeaux ruled on the setting-off of losses on land (usufructuary or bare owner) realised by splitted SCI in a decision of 15 March 2016*.

This website, created by Pierre Appremont, partner specialised in tax law and lecturer in real estate taxation at the ICH-CNAM (Institute of Economic and Legal Studies in the Real Estate, Construction and Housing Sectors), is intended to provide essential information on the tax issues relating to real estate.